Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N7463
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-N7463-2014
Breitburn Operating LP
Elmer Fudd East Central Production Facility
SRN: N7463
Located at
NE/4 SE/4 Section 7, T28N, R2E, Boiling Springs Road, Comins, Oscoda County, Michigan 48619
Permit Number:
MI-ROP-N7463-2014
Staff Report Date:
December 30, 2013
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution
Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act
451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ),
Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions
of the Renewable Operating Permit (ROP).
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TABLE OF CONTENTS
DECEMBER 30, 2013 - STAFF REPORT
3
JANUARY 29, 2014 - STAFF REPORT ADDENDUM
7
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N7463
RENEWABLE OPERATING PERMIT
DECEMBER 30, 2013 - STAFF REPORT
ROP Number
MI-ROP-N7463-2014
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s
Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to
the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a
stationary source’s applicable requirements and compliance with them by consolidating all state and
federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the
draft permit terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any
determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the
stationary source.
General Information
Stationary Source Mailing Address:
Breitburn Operating LP
P.O. Box 1256
Gaylord, Michigan 49735
N7463
2911
Source Registration Number (SRN):
North American Industry Classification System
(NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial Issuance?
Application Number:
Responsible Official:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
1
Renewal
201300020
Mr. Brian Dorr, Northern Division Manager
989-732-0020
William Rogers, Environmental Quality Analyst
989-705-3406
January 31, 2013
February 5, 2013
Yes
December 30, 2013
January 29, 2014
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Source Description
The Elmer Fudd East Central Production Facility is a natural gas production facility located on Boiling
Springs Road in Oscoda County, approximately four miles northwest of Comins. It process natural gas
from wells which produce from the Antrim Shale. The facility does not produce "sour gas," gas which
contains significant amounts of hydrogen sulfide. Antrim Formation gas is not known to contain
significant amounts of hazardous air pollutants as defined by the United States Environmental Protection
Agency.
The facility includes three natural gas-fueled reciprocating engines to compress gas and send it to a
production pipeline for further processing. The facility includes a glycol dehydrator to remove water from
the gas, and methanol storage equipment totaling less than 5000 gallons for all equipment.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2012 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
Tons per Year
58.0
0
79.5
0
0.06
11.3
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases in tons per year of CO2e is less than 100,000 tons. CO2e is a calculation of the
combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are
subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff
Report and identified in Part E of the ROP.
The stationary source is located in Oscoda County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because
the potential to emit nitrogen oxides exceeds 100 tons per year.
The stationary source is not considered a major source of hazardous air pollutants because the potential
emissions of any single hazardous air pollutant regulated by the Clean Air Act, Section 112, is less than
10 tons per year and the potential emissions of all hazardous pollutants combined is less than 25 tons
per year.
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No emissions units at the stationary source are currently subject to the Prevention of Significant
Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act
451, because at the time of New Source Review permitting the potential to emit of nitrogen oxides was
less than 250 tons per year. However, modifications at this stationary source may be subject to PSD
regulations.
The three natural gas-fueled engines EUENGINE1, EUENGINE2, and EUENGINE3 are subject to the
National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion
Engines for Area Sources promulgated in 40 CFR, Part 63, Subparts A and ZZZZ.
The glycol dehydration system EUDEHY is subject to the National Emission Standards for Hazardous Air
Pollutants for Oil and Natural Gas Production Facilities for Area Sources promulgated in 40 CFR, Part
63, Subparts A and HH.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring
Submittals."
No emission units are subject to the federal Compliance Assurance Monitoring rule under 40 CFR, Part
64, because all emission units at the stationary source either do not have a control device or those with a
control device do not have potential pre-control emissions over the major source thresholds.
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary
source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a
footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-N7463-2008 are identified in Appendix 6 of the ROP.
PTI Number
240-05A
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and
213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the
AQD, if any were proposed in the application. These determinations are incorporated into the permit
shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
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Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under
Rule 212(4). These processes are not subject to any process-specific emission limits or standards in
any applicable requirement.
Exempt
Emission Unit ID
EUHEATERS
Description of
Exempt Emission Unit
Miscellaneous natural gas fired
heaters, each having a maximum
heat input of less than 50 million BTU
per hour
Rule 212(4)
Exemption
R336.1212(4)(b)
Rule 201
Exemption
R336.1282
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree
upon pursuant to Rule 214(2).
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public
and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit.
In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the
draft permit and related material. The AQD is not required to accept recommendations that are not
based on applicable requirements. The delegated decision maker for the AQD is Janis Denman,
Cadillac District Supervisor. The final determination for ROP approval/disapproval will be based on the
contents of the permit application, a judgment that the stationary source will be able to comply with
applicable emission limits and other terms and conditions, and resolution of any objections by the
USEPA.
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
N7463
RENEWABLE OPERATING PERMIT
JANUARY 29, 2014 - STAFF REPORT ADDENDUM
ROP Number
MI-ROP-N7463-2014
Purpose
A Staff Report dated December 30, 2013, was developed in order to set forth the applicable
requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as
required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant
comments received on the draft ROP during the 30-day public comment period as described in
R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these
pertinent comments.
General Information
Responsible Official:
AQD Contact:
Mr. Brian Dorr, Northern Division Manager
989-732-0020
William Rogers, Environmental Quality Analyst
989-705-3406
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
Changes to the December 30, 2013 Draft ROP
No changes were made to the draft ROP.
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